December 16, 2019

CAMs: PCAOB’s Staff Observations (So Far)

Last week, the PCAOB released this Staff report with observations about how the CAMs are looking so far. Here’s an excerpt from this blog by Stinson’s Steve Quilivan:

As a starting matter, the PCAOB’s report seems to implicitly and perhaps explicitly assume that its audit standard requiring the reporting of CAMs provides “more useful and timely information.” That assumption is not backed up with any empirical data or observations.

The PCAOB apparently reviewed 12 of 189 audit reports through November 30, 2019 containing CAMs and there is no information about whether this observation set is statistically significant. The report promises that fuller analysis will follow. The observations reported by the PCAOB are general in nature and far from startling or, perhaps to many, useful.

Open Commission Meeting: Resource Extraction & Accredited Investors/QIBs

According to this notice, the SEC will hold an open Commission meeting this Wednesday to propose resource extraction rule changes and also to propose changes to the “accredited investor” and “QIB” definitions.

State of the SEC: A Few Nuggets from the Chair’s Testimony

Recently, SEC Chair Jay Clayton delivered this 33-page testimony to the Senate Banking Committee in a hearing about SEC oversight. Here are a few nuggets:

1. The SEC has 4400 employees. I’m always intrigued by keeping track of that stat for some reason. 140 positions were filled over the agency’s last fiscal year.

2. 34 rulemakings were advanced – quite a big number considering the government was closed for a month.

3. Proxy plumbing rulemakings took place. Been a lot of talk about proxy plumbing for over a decade. But this year saw a lot of concrete action.

4. Facilitating capital formation – a lot of action also took place here over the past year. “Testing the waters,” Fast Act, etc.

5. Human capital disclosure – on page 9, the Chair offers his own personal observation on this topic. Clearly, he believes in modernizing this area of disclosure.

Contingency Disclosures: Corp Fin’s Comments on Boeing

In this blog, Bass Berry’s Jay Knight analyzes how Corp Fin recently commented upon Boeing’s contingency disclosures. It serves as a nice reminder about the Fast Act rule changes…

Broc Romanek